[CT 7507]

HUB LAW OFFICES
Ford Greene, Esquire
California State Bar No. 107601
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1949
Telephone: (415) 258-0360

Attorney for Defendant
GERALD ARMSTRONG

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES

GARRY L. SCARFF declares:

1. My name is GARRY L. SCARFF. I live at 2137 N.E. Weidler St., Portland, Oregon 97232. My telephone number is (503) 281-9088. I am above the age of eighteen years old and provide the following testimony of my own first-hand knowledge. I could and would provide the same testimony in open court were I required to do so.

2. From 1982 through August 1992, I was a member of the CHURCH OF SCIENTOLOGY. For the two years preceding 1992 I was an operative of SCIENTOLOGY in the Los Angeles area where I have

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[CT 7508]

worked closely with EUGENE INGRAM, a licensed private investigator whose income is solely derived from SCIENTOLOGY.

3. EUGENE INGRAM, at the direction of SCIENTOLOGY, has attempted to ruin FORD GREENE on a personal and professional basis because of his activities on behalf of the Cult Awareness Network, his outspoken and public criticism of SCIENTOLOGY, his representation of former Scientologists, particularly Richard and Vicki Aznaran, and his current working relationship with GERALD ARMSTRONG, a former high-ranking Scientologist.

4. The operations against FORD GREENE are coordinated through the CHURCH OF SCIENTOLOGY INTERNATIONAL in Los Angeles. In this regard, I knew that the person who directed and controlled these operations was DAVID MISCAVIGE, the head of Scientology.

5. In 1987 I was directed by SCIENTOLOGY to represent myself as a survivor of the People's Temple immolation in Jonestown, Guyana and befriend FORD GREENE in order to perpetrate a Scientology operation on him. During Christmas 1987 FORD invited me to spend the holiday with him. When I was in his office alone during that period of time, I availed myself of his confidential legal records, legal files of his clients, a rolodex of his contacts and photographed his office.

6. In approximately September 1991 at a McDonald's Restaurant located in Albany, Oregon, EUGENE INGRAM showed me a letter to the Federal Bureau of investigation which I read. The letter from INGRAM stated that FORD GREENE was involved in the trafficking of drugs and the misuse of his law office by trading homosexual favors for the rendering of legal services. INGRAM frequently discussed his desire to have FORD GREENE indicted under

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[CT 7509]

the RICO statutes.

7. On or about December 20, 1991, I attended a meeting at SCIENTOLOGY's OFFICE OF SPECIAL AFFAIRS in Los Angeles where the law offices of BOWLES and MOXON are located. Present at that meeting were the following individuals: KENDRICK MOXON, TIMOTHY BOWLES, RANDY SPENCER and ERIC MORAN, all of whom are attorneys at Scientology's in-house law firm, BOWLES AND MOXON. Also present were EUGENE INGRAM, and DAVID BUTTERWORTH, the director of Scientology's OFFICE OF SPECIAL AFFAIRS. One purpose of this meeting was to develop a plan to destroy the personal and professional credibility of FORD GREENE and to continue attempts to have him disbarred from practicing law because he represented litigants against SCIENTOLOGY. The operations that were proposed and developed at this meeting included the following:

a. To create a public scheme portraying FORD GREENE as a sex fiend. This was to be accomplished through EUGENE INGRAM's manipulation of Margery Wakefield, a former client of FORD GREENE with a history of mental instability. INGRAM was to go to Florida and dupe Ms. Wakefield into signing a declaration that would be detrimental to FORD GREENE.

b. INGRAM asked me to execute a declaration stating that when I stayed with FORD GREENE over the Christmas holidays in 1987 Ford induced me to get drunk on alcohol and stoned on marijuana at which time INGRAM told me to state that FORD sodomized me and forced me to orally copulate him. INGRAM also told me to state that I did not admit to this in an earlier (false) declaration because FORD was to have threatened to send his drug dealer

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contacts to kill me if I stated anything of the homosexual attack.

c. INGRAM also wanted me to swear that FORD GREENE was a paying and frequent patron of a San Francisco bathhouse, that FORD GREENE was infected with the AIDS virus, and was intentionally passing it to others.

d. INGRAM also sought to expand on what he called the "fuck buddy" relationship between FORD GREENE and GERALD ARMSTRONG. One of INGRAM's suggestions was to set FORD GREENE up with a new male client who then would provide a declaration swearing that GREENE agreed to barter his legal services in return for sex.

e. Another of INGRAM's suggestions was that I go to San Anselmo and break into and enter GREENE's office when he was not present and plant cocaine and child pornography in his desk and then advise the police of GREENE's illegal possessions.

f. Ingram also suggested tampering with FORD GREENE's automobile by severing its brakes lines in order to produce a serious accident. When I said to Ingram that it could also kill GREENE, INGRAM responded, "There's no loss in a dead fag." INGRAM also suggested orchestrating an accident involving GREENE on the Golden Gate Bridge that would result in GREENE's car going over the side of the Bridge.

g. INGRAM and SCIENTOLOGY have also attempted to have GREENE disbarred by filing complaints with the State Bar.

8. At the instigation of EUGENE INGRAM, DAVID BUTTERWORTH and the aforementioned attorneys in BOWLES AND MOXON I have executed declarations in which I made false statements of fact. With respect to FORD GREENE, the false statements of fact that I made included, but were not limited to, the following:

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[CT 7511]

a. FORD GREENE is a homosexual. The truth is I have no basis for this statement;

b. FORD GREENE frequented the Castro Street area (a gay area) in San Francisco. I have no factual basis for this statement;

c. While nude FORD GREENE hugged me and would not let go. This is false.

d. GREENE took a picture of me, naked, as I was leaving the shower. This is false.

9. INGRAM, BUTTERWORTH and lawyers at BOWLES AND MOXON repeatedly expressed that they would do anything to prevent GERALD ARMSTRONG and FORD GREENE from working together.

Pursuant to the laws of the State of California, I hereby declare the foregoing to be true and correct.

Executed on February 11, 1993 at Portland, Oregon.

[Signed] Garry L. Scarff

GARRY L. SCARFF